Whistleblowing Policy

Macro Tech Ventures Sdn. Bhd. (formerly known as Dropee) and its subsidiaries and related companies ("Borong", "the Company")

1. Purpose

Borong is committed to conducting its business with honesty, integrity, transparency and accountability, and to maintaining the highest standards of ethical conduct across its operations, including Borong Direct, Borong Marketplace and Borong Credit. An essential part of this commitment is ensuring that anyone who becomes aware of improper conduct involving Borong, whether committed by an employee, a director, a vendor, a business partner or any person acting on the Company's behalf, is able to raise that concern safely, confidentially and without fear of reprisal.

This Policy establishes the framework through which such concerns can be reported, explains how reports are handled and investigated, and sets out the protections afforded to those who speak up in good faith. Early reporting helps the Company identify and eliminate misconduct, protect its people, its customers and its reputation, and prevent losses or damage before they escalate.

2. Who May Report

This Policy is deliberately broad in scope. Reports may be made by any internal or external stakeholder, including:

Employees of Borong, whether full-time, part-time, fixed-term contract, contract for service, probationary or interns;
Directors and officers of the Company;
Vendors, suppliers, merchants and sellers transacting on or through the Borong platform;
Customers, buyers and users of Borong's products and services;
Business partners, agents, consultants, contractors and service providers; and
Members of the public.

No prior relationship with Borong is required in order to make a report under this Policy.

3. What Should Be Reported

A "reportable concern" is any information which a person reasonably believes shows past, present or likely future misconduct or wrongdoing connected with Borong. Reportable concerns include, but are not limited to:

Bribery, corruption, kickbacks, or the giving or receiving of gifts in breach of the Borong Anti-Bribery & Anti-Corruption Policy;
Fraud, theft, embezzlement, misappropriation of Company assets or falsification of records;
Forced labour, child labour, human trafficking, debt bondage or other human rights violations, whether within Borong or its supply chain;
Sexual harassment, workplace harassment, bullying, mobbing, discrimination or victimisation;
Breaches of applicable laws, regulations or licensing conditions;
Money laundering, terrorism financing or sanctions evasion;
Misuse, theft or unauthorised disclosure of confidential information, trade secrets or personal data;
Conduct that endangers the health or safety of any person, or that causes damage to the environment;
Irregularities in financial reporting, accounting, audit or internal controls;
Abuse of position, conflicts of interest, or misuse of Company resources; and
Any deliberate attempt to conceal, destroy evidence of, or obstruct the investigation of, any of the above.

Ordinary commercial disputes, service complaints or refund requests should be raised through Borong's customer support channels in the first instance; however, where such a matter involves suspected misconduct, it may also be reported under this Policy.

4. How to Report

Reports may be made through any of the following channels:

Email: report@borong.com
Letter: Head of People & Culture, Borong, Suite 13.02, Level 13, Menara IGB, Mid Valley City, Lingkaran Syed Putra, 59200 Kuala Lumpur, Malaysia

Where a report concerns the Head of People & Culture, or where the whistleblower reasonably believes the ordinary channels are compromised, the report may be addressed directly to the Chief Executive Officer or the Board of Directors at the same address.

Reports may be made anonymously. Whistleblowers are encouraged, but never required, to identify themselves, because anonymity may limit the Company's ability to seek clarification, investigate fully, protect the whistleblower proactively, or provide updates on the outcome. Whether or not a whistleblower identifies themselves, they should, where possible, provide sufficient detail for the matter to be investigated, including a description of the conduct, the parties involved, relevant dates, locations and transactions, how the whistleblower became aware of the matter, and any supporting documents or evidence.

5. Confidentiality

Borong treats the identity of a whistleblower, and the contents of a report, as strictly confidential. Access to this information is restricted to those persons who genuinely need it in order to assess, investigate or act on the report. Confidential information relating to a report will not be disclosed except where the whistleblower consents, where disclosure is necessary for a fair investigation or to afford the subject of the report a fair opportunity to respond, or where disclosure is required by law, by a regulator, or by an order of court. Where disclosure becomes necessary, the Company will, where practicable, inform the whistleblower beforehand.

6. Protection Against Retaliation

Borong strictly prohibits retaliation, in any form, against any person who makes a report in good faith under this Policy, or who participates or assists in an investigation. Retaliation includes, without limitation: dismissal, demotion, suspension or any other adverse employment action; harassment, intimidation, discrimination or victimisation; the termination, suspension or adverse variation of a commercial or platform relationship; blacklisting; and any threat to do any of the foregoing.

Any employee found to have retaliated, or attempted or threatened to retaliate, against a whistleblower will face disciplinary action up to and including termination of employment. Any vendor, supplier or business partner found to have done so may have its contract or platform access suspended or terminated. A person who believes they have suffered retaliation should report it immediately through the channels in Section 4, and such reports will themselves be treated as reportable concerns and investigated.

In addition to the protections in this Policy, whistleblowers who make disclosures of improper conduct to the appropriate enforcement agencies in accordance with the Whistleblower Protection Act 2010 may be entitled to the statutory protections conferred under that Act, including protection of confidential information, immunity from civil and criminal action, and protection against detrimental action.

7. Assessment and Investigation

All reports received are logged, acknowledged where contact details are available, and assessed promptly to determine whether the matter falls within this Policy and warrants investigation. Where an investigation is warranted, it will be conducted:

Promptly, with the objective of completing investigations within a reasonable timeframe proportionate to the complexity of the matter;
Fairly and objectively, by persons who have no personal interest or conflict of interest in the matter, and with escalation to the Chief Executive Officer or the Board where the seniority of the persons involved requires it;
With due process, respecting the presumption of innocence; any person who is the subject of a report will be given a fair opportunity to be heard and to respond to the allegations before any adverse finding or decision is made; and
Confidentially, in accordance with Section 5.

Where a violation is substantiated, the Company will take appropriate corrective and disciplinary action, which may include counselling, warning letters, duty exemption, demotion, salary reduction, termination of employment, or the suspension, delisting or termination of a vendor or partner relationship. Matters will be referred to the relevant regulatory or enforcement authorities where required by law or where the Company considers referral appropriate. Where contact details are available, the whistleblower will be informed, to the extent appropriate and lawful, that the matter has been concluded.

8. False or Malicious Reports

No action will be taken against a person who makes a report in good faith, even if the concern is not subsequently substantiated. The protection of this Policy does not, however, extend to reports that are made maliciously, in bad faith, frivolously, or which the reporter knows to be false. Such reports undermine genuine whistleblowing and may result in disciplinary action, termination of a commercial relationship, or legal action.

9. Roles, Oversight and Review

The Head of People & Culture is responsible for the day-to-day administration of this Policy, including receiving, logging and coordinating the assessment of reports. The Chief Executive Officer owns this Policy and is accountable for its effective implementation. The Board of Directors provides oversight, receives periodic reporting on whistleblowing matters, and approves material amendments to this Policy.

This Policy is reviewed periodically, and at minimum whenever there is a material change in applicable law, regulatory expectations or the Company's business, to ensure it remains effective, accessible and fit for purpose.